CareerLabsVR Privacy Policy

 

PRIVACY POLICY

This privacy policy (the “Policy”) is based on the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).  It governs the relationship between CareerLabsVR Inc. (“we”, “us”, etc.) and individuals with whom we interact, such as our customers or potential customers, website users, contractors, and other stakeholders (“you”).

  1. SCOPE AND APPLICATION

“Personal information” is information that may be used to identify a specific individual.  Examples include your name, address, telephone number, email address, age, and other personal identification numbers such as a social insurance number.

  1. PURPOSES

2.1.       We collect and use personal information for purposes reasonably required to carry on our business and provide products and services to you.  We will identify the purposes for which personal information is collected at or before the time of collection.  Some of these purposes include:

  • to confirm your identity and contact information;
  • to establish and maintain a responsible commercial relationship with you;
  • to market and provide products and services to you, or provide information to you about our products and services;
  • to manage, develop, and improve our operations so we can deliver better products and services;
  • to understand your needs from time to time; and
  • to meet legal, regulatory, and contractual obligations to you and to others;

You acknowledge having been made aware of the above-noted purposes.

2.2.       If we identify a new purpose for the personal information we have already collected from you, we will obtain your consent before using it for the new purpose.

  1. CONSENT

3.1.       We will only collect, use, or disclose your personal information with your consent, except in limited circumstances.  Such consent is a condition of the supply of a product or service if the collection, use, or disclosure of your personal information is required to fulfill the identified purposes. In determining the appropriate form of consent, we will take into account the sensitivity of the personal information and reasonable expectations.  Your use of our products and services constitutes implied consent for us to collect, use, and disclose personal information for all identified purposes.  

3.2.       You may withdraw or limit your consent at any time, subject to any legal or contractual restrictions and reasonable notice.  Please note that the withdrawal of your consent may change the way in which we are able to interact with you and provide you with products and services.

  1. LIMITING COLLECTION

4.1.       We limit the collection of personal information to that which is necessary for the purposes identified in this Policy or otherwise identified before or at the time of collection. 

4.2.       We generally collect personal information directly from you but may also collect personal information from other sources who properly represent that they have the right to disclose the information.  We only collect personal information by lawful means.

  1. LIMITING USE, DISCLOSURE, AND RETENTION

5.1.       We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent, or as required in certain situations, including:

  • to comply with a subpoena, warrant, or other court order, or as otherwise required by law;
  • in the context of an investigation of a contravention of federal or provincial law, where collection and use of the personal information is reasonable and useful, and seeking consent would compromise the availability or accuracy of such information;
  • for an emergency that threatens life, health, or security;
  • for the purposes of collecting on a debt owed to us;
  • in the context of obtaining advice from a lawyer or other professional advisor;
  • to an affiliated company or a third-party service provider where the third-party has agreed to handle the information in accordance with our standards and applicable legislation;
  • to a person we reasonably believe to be acting as your agent;
  • for the purposes of a proposed sale of all or part of our business; or
  • if the information is publicly available;

5.2.       Once personal information is no longer necessary or relevant for the identified purposes, nor required by law to be retained, it will be destroyed, erased, or made anonymous.

  1. ACCURACY

6.1.       We make efforts to keep personal information accurate, complete, and up-to-date in order to fulfill the identified purposes and to minimize the possibility that inaccurate information about you may be used.  We may reach out to you from time to time to verify your personal information.  We will promptly correct or complete any personal information found to be inaccurate or incomplete.

6.2.       Should you with to update or change your personal information, please contact our Privacy Officer (see section 10.2).

  1. SAFEGUARDS

7.1.       We will employ appropriate security measures to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction.  Such safeguards will be appropriate to the sensitivity of the information.  Some of those safeguards include:

  • limiting the collection, use, and disclosure of personal information to that reasonably required to carry on our business and provide you with our products and services;
  • ensuring that areas and documents are only accessible by authorized personnel on a need-to-know basis;
  • protecting the confidential nature of personal information when dealing with other organizations and requiring them to meet the same standards we do in handling personal information.

7.2.       From time to time, we may use third-party service providers to process information on our behalf, including for payment processing, human resources administration, and similar purposes. In those cases, your personal information may be made available to these third parties.  In addition, we may store your information in electronic databases or e-mail systems hosted by us or by our service providers.  Please note that we use cloud-based solutions and the data collected may reside in data centers outside of Canada.  We do not sell or trade your personal information to other organizations or companies.

7.3.       We will keep a record of all security breaches, if any.  If it is reasonable in the circumstances to believe that a breach creates a real risk of significant harm to individuals, we will:

  • notify the individuals concerned as soon as feasible after we have determined that the breach involves such risk for harm; and
  • report the breach to the Privacy Commissioner of Canada.
  1. ACCESS

8.1.       You have the right to ask whether we hold any personal information about you and, if so, to make reasonable requests to review, update, or correct your personal information.  We will respond to your request for access within 30 days of the request being made to us in writing.  Such access will be granted to you at minimal or no cost. 

8.2.      There are situations where we may not be able to provide you with access to all the personal information we have about you.  For example, we would not be able to provide information if doing so would likely reveal personal information about someone else.  We also may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law.  If access to personal information cannot be provided, we will provide the reasons for denying access upon request.

8.3.       In order to safeguard personal information, you may be required to provide sufficient identification information to permit us to identify you and account for the existence, use, and disclosure of your personal information.

  1. PRIVACY OFFICER.

9.1.       If you wish to access your personal information, change your consent to the ways in which we may use your personal information, have a complaint about our Policy or the manner in which we may have handled your personal information, or if you have any questions about our Policy or the purposes identified in this Policy, you may contact our Privacy Officer as follows:

            Email: info@careerlabsvr.com;   Phone: 613-498-2111

 

  1. CHALLENGING COMPLIANCE

You are able to address a challenge concerning our compliance with PIPEDA and this Policy to our Privacy Officer.  We will investigate all complaints and, if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our policies and procedures.  We will inform you of the outcome of the investigation regarding your complaint. 

  1. CHANGES TO THIS POLICY

In order to ensure our Policy is kept up to date, we reserve the right to change it from time to time.  Any changes will be effective when posted to our website.  Please periodically review our Policy to ensure you are informed of our current practices.

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